Intero Real Estate Services, Inc. values you as our customer
and we want to address any privacy concerns you may have. To that end, we have
set forth our privacy policy for handling the information you share with us online
and through any documentation submitted as part of a real estate transaction
with Intero Real Estate Services, Inc. We want your decision to do business
with us to be an informed one. We have adopted this Privacy Policy to explain
what information may be collected when you utilize our applications and
services, how we use this information, and under what circumstances we may
disclose the information to affiliates and third parties. You should review
this Privacy Policy frequently, as it may change from time to time without
notice. Any changes will be effective immediately upon the posting of the
revised Privacy Policy.

1. Scope of Our Privacy Notice

This privacy notice applies to our collection, use
disclosure and other processing of personal information related to:

The use of our Sites or Services that display or link to
this Policy

Former, current and prospective clients, brokers,
independent agents, and consumers

Other individuals who use our Sites or Services, whose
personal information we received related to the Sites and Services

All collection, use, disclosure, and processing of personal
information by Intero about individuals will vary depending upon use of our
Sites and Services. This policy is intended to provide our general practices
and procedures. In some cases, different or additional notices about our data
collection and processing may be provided and apply to certain personal
information.

This policy does not apply to job applicants or
candidates who apply for employment with Intero or to our employees and
independent agents.

2. Collecting Information

When you visit our consumer applications or purchase and/or
sell real estate with Intero, we may collect information about you that you
share with us. We typically collect two kinds of information about you through
our applications and real estate services: (a) information that you provide
that personally identifies you; and (b) information that does not personally
identify you, which we automatically collect when you visit our applications or
that you provide to us.

Personally Identifiable Information: This
identification information may include, but is not limited to, your name,
physical address, email address, telephone, mobile and fax numbers,
details of your real estate, lending, title and insurance needs and
references, and other details of your life (“Personal Information”).

Non-Personally Identifiable Information: Our
definition of non-personally identifiable information is any information
that does not personally identify you (“Non-PII”). Non-PII can include
certain personally identifiable information that has been de-identified;
that is, information that has been rendered anonymous by a
de-identification process. We obtain Non-PII about you from information
that you affirmatively provide to us, either separately or together with
your personally identifiable information. We also automatically collect
certain Non-PII from you when you access any applications. This
information can include, among other things, IP addresses, the type of browser
you are using, the third-party website from which your visit originated,
the operating system you are using, the domain name of your Internet
service provider, the search terms you use on our applications, the
specific web pages you visit, the duration and frequency of your visits,
and location information.

Cookies, Web Beacons and other Tracking
Technologies: As you may be aware, it is a common practice that
when you visit our consumer applications, we may collect data through the
use of cookies, web beacons or other tracking technologies (i.e. small
text files placed on your computer by consumer applications), web server
logs, and other web tools. This technology allows us to customize your
online experience as well as track your use of our system so that we can
improve your experience. The tracking data we collect may include, but is
not limited to, the date, time and location of your visit, the time you
spend, the web pages you view, the other consumer applications you visit,
your search queries, and basic information about your computer, such as
your Internet Protocol (“IP”) address, your domain name, your browser
type, and the name of your internet service provider. By continuing to
browse our site, you are agreeing to our use of cookies. Most web browsers
automatically accept cookies, but will also provide controls that allow
you to block or delete them. Instructions for blocking or deleting cookies
are generally available in your browser’s privacy or help documentation.
If you choose to delete cookies, some settings and preferences controlled
by those cookies, including advertising preferences, will be deleted and
may need to be recreated. You may deactivate cookies if you do not want
your browsing to be tracked.

When visiting our consumer-facing applications, you may be
directed, through hyperlinks, to other consumer applications that are beyond
our control. This Privacy Policy does not cover the collection of information
by those other companies and consumer applications. Although we encourage third
parties to provide their own privacy policies, we are not responsible for their
activities, such as how they handle the information they collect online.

You can manage how your preferences regarding third party ad
company cookies set by this Site or Service by reading the cookie discussion
above.

Please also see the cookie discussion above for information
about the third parties we may work with to display targeted ads on third-party
sites and to measure the success of our marketing and campaigns. You may also
obtain more information about targeted or “interest-based advertising” and
opt-out of many ad networks at the industry websites below:

Certain laws, including the EU General Data Protection
Regulation (“GDPR”), requires that we inform applicable individuals of the
legal basis for our use and other processing of personal information.

We process personal information for the follow bases:

Performance of contract: as necessary to enter
into or carry out the performance of our contract

Compliance with laws: for compliance with
legal obligations and/or defense against legal claims, including those in
the area of labor and employment law, social security, and data
protection, tax, and corporate compliance laws.

Fraud prevention, including misuse of company IT systems
or money laundering

Physical, IT, and network perimeter security

Internal investigations

Mergers, acquisitions, and reorganization, and other
business transactions

With your consent: where we have your consent
(the GDPR (where it applies)) and other applicable laws give you the right
to withdraw your consent, which you can do this at any time by contacting
us using the details at the end of this privacy notice. In some
jurisdictions, your use of the Services may be taken as implied consent to
the collection and processing of personal information as outlined in this
privacy notice.

In addition, we may process your personal information where
necessary to protect the vital interests of any individual.

4. How We Use & Share Information Collected

Personal Information: We primarily use the
identification information you voluntarily share with us to:

Contact you for a variety of reasons, such as providing
you promotional or marketing information for our products or those of our
affiliated companies;

Communicate with you about your real estate transaction;

In certain instances, we may also share your personally
identifiable information with our third-party vendors and marketing
partners that, among other activities: perform functions on our behalf
(or on behalf of our affiliated companies); administer our offerings;
provide us marketing or promotional assistance; analyze our data; assist
us with customer service; and offer other services and products that may
be relevant to the purchase or sale of real estate. Our vendors agree to
use this information, and we share information with them, only to carry
out our requests;

On occasion, we use your identification information to
validate your identity;

As for usage tracking data, we primarily use that
information to operate and improve our consumer applications, and to
further our marketing efforts.

You may opt-out from receiving future promotional or
marketing information from us, our affiliated companies, and our third-party
vendors, or direct that we not share your information with any affiliated
companies or third-party vendors, as set forth below in Section 10. Except as
provided in this Privacy Policy, our Terms of Use, or as set forth when you
submit the information, your personally identifiable information will not be
sold to any third parties or used in any manner outside the scope of this
Privacy Policy without your prior approval. We further reserve the right to
disclose your information under limited circumstances, such as to cooperate
with law enforcement or judicial authorities as required by law or legal
process, to protect our own legal rights, or to protect the public good.

Non-PII: We use Non-PII in a variety of ways,
including to:

Help analyze site traffic, understand customer needs and
trends;

Carry out targeted promotional activities;

Improve our services and offerings.

We may use your Non-PII by itself or aggregate it with
information we have obtained from others. We may share your Non-PII with our
affiliated companies and third parties to achieve these objectives and others,
but remember that aggregate information is anonymous information that does not
personally identify any individual, device, or household.

Whenever you are online or on our applications, you run the
risk that the information you provide will fall into the wrong hands.
Although we implement and maintain commercially reasonable security procedures
and practices to safeguard your privacy, we cannot guarantee the security of
any information you provide to us. We accept no responsibility or liability for
the activities of third parties. By using our consumer applications and
applications, you agree to our Terms of Use.

5. Updating Information

If you would like to review the information about you that
we have collected through our consumer applications, or to change that
information, you can make that request by following the procedure indicated
below in Section 10. We may require that you verify your identity before we
process your request.

6. Processing Location

We process your personal information in the United States.
For users located outside of the United States, please see Sections 16 titled
European Union / European Economic Area for more detailed information.

7. Anti-Fraud Disclosure

Electronic communications such as email, text messages and
social media messaging, are neither secure nor confidential. While Intero has
adopted policies and procedures to aid in avoiding fraud, even the best
security protections can still be bypassed by unauthorized parties. Intero will
never send you any electronic communication with instructions to transfer funds
or to provide nonpublic personal information, such as credit card or debit
numbers or bank account and/or routing numbers.

YOU SHOULD NEVER TRANSMIT NONPUBLIC PERSONAL INFORMATION,
SUCH AS CREDIT OR DEBIT CARD NUMBERS OR BANK ACCOUNT OR ROUTING NUMBERS, BY
EMAIL OR OTHER UNSECURED ELECTRONIC COMMUNICATION. EMAILS ATTEMPTING TO INDUCE
FRAUDULENT WIRE TRANSFERS ARE COMMON AND MAY APPEAR TO COME FROM A TRUSTED
SOURCE.

If you receive any electronic communication directing you to
transfer funds or provide nonpublic personal information, EVEN IF THAT
ELECTRONIC COMMUNICATION APPEARS TO BE FROM Intero or its affiliates, do not
respond to it and immediately contact your real estate agent or title closer.
Such requests, even if they may otherwise appear to be from Intero, are likely
part of a scheme to defraud you by stealing funds from you or using your
identity to commit a crime.

We may, from time to time, change our Privacy Policy. We
will notify you of any changes by posting our updated Privacy Policy on our
consumer applications and inserting a new “Effective Date.”

9. Data Retention

We will retain your personal information for the period
necessary to fulfill the purposes outlined in this privacy notice unless a
longer retention period is required or permitted by law. We may retain personal
information for longer where required by our legal and regulatory obligations,
professional indemnity obligations, or where we believe it is necessary to
establish, defend or protect our legal rights and interests or those of others.
With respect to the data and files we handle as a processor, we retain this
personal information in accordance with our clients’ instructions.

10. Rights and “Opt-Out”

Marketing. You may opt out from receiving
marketing-related communications from us on a going-forward basis by contacting
us or by using the unsubscribe mechanism contained in each email. We will try
to comply with your request(s) as soon as reasonably practicable. Please note
that if you opt out of receiving marketing-related emails from us, we may still
send you important administrative messages, from which you cannot opt out.

Cookies and similar technologies. Please review
your browser or device settings for certain cookies and see above to exercise
certain choices regarding cookies.

Access, amendment and deletion. Under applicable
privacy laws, you may have the right to request to review, make amendments,
have deleted or otherwise exercise your rights over your personal information
that we hold, subject to certain legal limitations and requirements. If you are
subject to such a privacy law, you may submit a request to us related to your
personal information:

By submitting a request to us at Privacy@intero.com

By contacting us at (866)420-5700 (toll free)

We follow applicable law to take steps to keep your personal
information accurate, complete and up-to-date. In your request that is covered
by an applicable privacy law, please make clear what personal information you
would like to have changed, whether you would like to have your personal
information suppressed from our database or otherwise let us know what
limitations you would like to put on our use of your personal information. We
may only implement requests (a) where required by applicable law and (b) with
respect to the personal information associated with the particular email
address that you use to send us your request, and we may need to verify
your identity before implementing your request. We will try to comply with your
request as soon as reasonably practicable.

As outlined below, if you are a California resident or if
you are in the European Union/European Economic Area, you may have additional
rights.

Deactivation. You can deactivate your account at
any time by contacting us at the email address at the bottom of this page.
However, you will not be able to access many of the services to deactivate your
account. Please note that even if you request deactivation of your account, it
may take some time to fulfill this request.

Responding to Requests. Please note that we may
need to retain certain information for recordkeeping purposes and/or to
complete any transactions that you began prior to requesting a change or
deletion. There may also be residual information that will remain within our
databases and other records, which will not be removed. We may not always be
able to fully address your request, for example if it would impact the duty of
confidentiality we owe to others, or if we are legally entitled to deal with
the request in a different way.

Additional information for certain jurisdictions. We
are committed to respecting the privacy rights of individuals under all privacy
laws applicable to us. Some privacy laws require that we provide specific
information about individual rights to applicable consumers, which we have set
forth at the end of this privacy notice:

California: if you are a California resident,
you have certain rights, under California privacy laws, regarding your personal
information as set forth in Section 15 below.

EU/EEA: if you are in the European Union /
European Economic Area, we provide further details about your rights under the
GDPR in Section 16 below.

11. Children

The Services are not intended or directed to children under
the age of 18, and we do not knowingly collect any personal information, or
knowingly track the use of our Services, from children. If we have actual
knowledge that personal information about a child under 18 years old has been
collected, then we will take appropriate steps to try and delete such personal
information.

12. THIRD-PARTY WEBSITES

The Services may contain links to third-party services. We
do not own, operate, or control the websites of third-parties, including those
of independently owned and operated franchisees. Accordingly, this Policy does
not apply to any services maintained or operated by third-parties. When you
click on those links, you will go to a third-party website where you will be
subject to that service’s privacy policy or similar statement and terms of use,
and we encourage you to read that policy statement. We are not responsible for
the privacy practices of other services, and we expressly disclaim any
liability for their actions, including actions related to the use and
disclosure of personal information by those third parties.

13. Effective Date and Changes to this Policy

This Privacy Policy is effective as of January 1, 2020.

14. Contact Information

For questions and concerns about this Policy, our company
can be reached at:

Address: 10275 N. De Anza Blvd., Cupertino, Ca 95014

Email Address: Privacy@intero.com

Phone: Toll Free (866) 420-5700

15. California Privacy Rights

California Residents.

In this section, we provide information for California
residents, as required under California privacy laws, including the California
Consumer Privacy Act (“CCPA”), which requires that we provide
California residents certain specific information about how we handle their
personal information, whether collected online or offline. This section does
not address or apply to our handling of publicly available information made
lawfully available by state or federal governments or other personal information
that is subject to an exemption under the CCPA.

Categories of personal information that we collect. Our
collection, use and disclosure of personal information about a California
resident will vary depending upon the circumstances and nature of our interactions
or relationship with such resident. The table below sets out generally the
categories of personal information (as defined by the CCPA) about California
residents that we collect, sell, and disclose to others for a business purpose.
We collect these categories of personal information from the sources described
and for the purposes also detailed below.

Records of personal property, products or services
purchased, obtained, or considered, or other purchasing or consuming
histories or tendencies.

YES

E. Biometric information.

Genetic, physiological, behavioral, and biological
characteristics, or activity patterns used to extract a template or other
identifier or identifying information, such as, fingerprints, faceprints, and
voiceprints, iris or retina scans, keystroke, gait, or other physical
patterns, and sleep, health, or exercise data.

NO

F. Internet or other similar network activity.

Browsing history, search history, information on a
consumer’s interaction with a website, application, or advertisement.

We obtain the categories of personal information listed
above from the following categories of sources:

Information from you that you actively provide: We
collect this information from sources including from online forms, e-mail,
and via telephone.

Information from you that you provide passively from your
use of your sites and services: We collect this information from
sources including from a web browser, e-mail, app, or smartphone.

Third Parties (information we collect about you from third
party sources): We collect this from sources including marketing
partners, lead generators, and website and app vendors.

Use of Personal Information. We may use or
disclose the personal information we collect for one or more of the following
business purposes:

To fulfill or meet the services for which the information
is provided.

To provide you with information, products or services that
you request from us.

To provide you with email alerts, event registrations and
other notices concerning our products or services, or events or news, that
may be of interest to you.

To carry out our obligations and enforce our rights
arising from any contracts entered into between you and us, including for
billing and collections.

To improve our website and present its contents to you.

For testing, research, analysis and product development.

As necessary or appropriate to protect the rights,
property or safety of us, our clients or others.

To respond to law enforcement requests and as required by
applicable law, court order, or governmental regulations.

As described to you when collecting your personal
information or as otherwise set forth in the CCPA.

To evaluate or conduct a merger, divestiture,
restructuring, reorganization, dissolution, or other sale or transfer of
some or all of our assets, whether as a going concern or as part of
bankruptcy, liquidation, or similar proceeding, in which personal
information held by us is among the assets transferred.

We will not collect additional categories of personal
information or use the personal information we collected for materially
different, unrelated, or incompatible purposes without providing you notice.

Sharing Personal Information. We may disclose
your personal information to a third party for a business purpose. When
we disclose personal information for a business purpose, we enter a contract
that describes the purpose and requires the recipient to both keep that
personal information confidential and not use it for any purpose except
performing the contract.

In the preceding twelve (12) months, we have disclosed the
following categories of personal information for a business purpose:

We disclose your personal information for a business purpose
to the following categories of third parties:

Our affiliates.

Service providers.

Third parties to whom you or your agents authorize us to
disclose your personal information in connection with products or services
we provide to you.

Categories of Personal Information Sold. The
CCPA defines a “sale” as disclosing or making available to a third-party
personal information in exchange for monetary or other valuable consideration.
While we do not disclose personal information to third parties in exchange for
monetary compensation from such third parties, we do disclose or make available
the categories of personal information that we collect to our affiliate and subsidiary
companies. We also may make certain categories of personal information
available to third parties, in order to receive certain services or benefits
from them (such as when we allow third party tags to collect browsing history
and other information on our Services to improve and measure our ad campaigns),
including:

Rights of California residents. California law
grants California residents certain rights and imposes restrictions on
particular business practices as set forth below.

Do-Not-Sell: California residents have the
right to opt-out of our sale of their personal information Opt-out rights
can be exercised by clicking on the “Do Not Sell My Information” at the
bottom of this page or the homepage of our website. We do not sell
personal information about residents who we know are younger than 16 years
old without opt-in consent.

Initial Notice: We are required to notify
California residents, at or before the point of collection of their
personal information, the categories of personal information collected and
the purposes for which such information is used.

Request to Delete: California residents have
the right to request deletion of their personal information that we have
collected about them and to have such personal information deleted, except
where an exemption applies. We will respond to verifiable requests
received from California residents as required by law.

Request to Know: California residents have the
right to request and, subject to certain exemptions, receive a copy of the
specific pieces of personal information that we have collected about them
in the prior 12 months and to have this delivered, free of charge, either
(a) by mail or (b) electronically in a portable and, to the extent
technically feasible, readily useable format that allows the individual to
transmit this information to another entity without hindrance. California
residents also have the right to request that we provide them certain
information about how we have handled their personal information in the
prior 12 months, including:

categories of personal information collected;

categories of sources of personal information;

business and/or commercial purposes for collecting and
selling their personal information;

categories of third parties/with whom we have disclosed
or shared their personal information;

categories of personal information that we have disclosed
or shared with a third party for a business purpose;

categories of personal information collected; and

categories of third parties to whom the residents’
personal information has been sold and the specific categories of
personal information sold to each category of third party.

California residents may make a Request to Know up to twice
every 12 months. We will respond to verifiable requests received from
California residents as required by law.

Right to non-discrimination: The CCPA
prohibits discrimination against California residents for exercising their
rights under the CCPA. Discrimination may exist where a business denies or
provides a different level or quality of goods or services, or charges (or
suggests that it will charge) different prices, rates, or penalties
on residents who exercise their CCPA rights, unless doing so is reasonably
related to the value provided to the business by the residents’ data.

Financial incentives: A business may offer
financial incentives for the collection, sale or deletion of California
residents’ personal information, where the incentive is not unjust,
unreasonable, coercive or usurious, and is made available in compliance
with applicable transparency, informed consent, and opt-out requirements.
California residents have the right to be notified of any financial
incentives offers and their material terms, the right to opt-out of such
incentives at any time, and may not be included in such incentives without
their prior informed opt-in consent. We do not offer any such incentives
at this time.

Submitting Requests. Do-Not-Sell (Opt-out)
Requests, Requests to Know, and Requests to Delete may be submitted:

Do-Not-Sell: By clicking on the “Do Not Sell My
Information” at the bottom of this page or the homepage of our website.

Requests to Know, Requests to Delete: Submitting a
request to us at Intero.

All requests: By contacting us at (866)420-5700 (toll
free)

We will respond to verifiable requests received from
California residents as required by law. For more information about our privacy
practices, contact us as set forth in the “Contact Us” section above.

You may only make a verifiable consumer request to know
information twice within a 12-month period. We cannot respond to your request
or provide you with personal information if we cannot verify your identity or
authority to make the request and confirm that the personal information relates
to you. We will only use personal information provided in a verifiable consumer
request to verify the requestor’s identity or authority to make the request.

Once we receive your verifiable consumer request, we will
send you an acknowledgement letter within 10 days which will describe our
verification process. We will respond to your request within 45 days, if we are
able to verify your identity. Requests for deletion will require a separate
confirmation that you want your information deleted.

We do not charge a fee to process or respond to your
verifiable consumer request unless it is excessive, repetitive, or manifestly
unfounded. If we determine that the request warrants a fee, we will tell you
why we made that decision and provide you with a cost estimate before
completing your request.

Please note we are unable to disclose or provide you with
your Social Security Number, Driver’s License Number, or other government
issued identification number, financial account number, any health insurance or
medical identification number, an account password, or security questions and
answers.

Rights Under California Shine the Light law. California
residents may request from businesses with whom they have an established
business relationship (1) a list of categories of personal information , such
as name, address, e-mail address, and the type of services provided to the
customer, that a business has disclosed to third parties during the immediately
preceding calendar year for the third parties’ direct marketing purposes and
(2) the names and addresses of all such third parties. To request the above
information please contact us by writing to us under the “Contact Us” section
above. We will respond to such requests within 30 days of receipt.

Changes to Our Privacy Notice. Intero reserves
the right to amend this privacy notice at our discretion and at any time. When
we make changes to this privacy notice, we will post the updated notice on the
Website and update the notice’s effective date. Your continued use of our
Website or Services following the posting of changes constitutes your
acceptance of such changes.

16. European Union / European Economic Area

Individuals in the European Union (EU) and the European
Economic Area (EEA) have the following rights, under the GDPR, regarding their
personal information:

Right of access: You have the right to obtain
from us confirmation as to whether or not personal information concerning
you is being processed, and where that is the case, to request access to
the personal information. The accessed information includes – among others
– the purposes of the processing, the categories of personal information
concerned, and the recipients or categories of recipient to whom the
personal information have been or will be disclosed. You have the right to
obtain a copy of the personal information undergoing processing. For
further copies requested by you, we may charge a reasonable fee based on
administrative costs.

Right to rectify and complete personal
information: you can request the rectification of inaccurate data
and the completion of incomplete data. We will inform relevant third
parties to whom we have transferred your data about the rectification and
completion if we are legally obliged to do so.

Right to erasure (right to be forgotten): You
have the right to obtain from us the erasure of personal information
concerning you in limited circumstances where:

it is no longer needed for the purposes for which it was
collected; or

you have withdrawn your consent (where the data
processing was based on consent); or

following a successful right to object; or

it has been processed unlawfully; or

the data has to be erased in order to comply with a legal
obligation to which we are subject.

We are not required to comply with your request to erase
personal information if the processing of your personal information is
necessary for:

compliance with a legal obligation; or

the establishment, exercise or defense of legal claims.

Right to restriction of processing: You have
the right to obtain from us restriction of processing your personal
information. In this case, the respective data will be marked and only be
processed by us for certain purposes. This right can only be exercised
where:

the accuracy of your personal information is contested,
to allow us to verify its accuracy; or

the processing is unlawful, but you do not want the
personal information erased; or

it is no longer needed for the purposes for which it was
collected, but you still need it to establish, exercise or defend legal
claims; or

you have exercised the right to object, and verification
of overriding grounds is pending.

We can continue to use your personal information following a
request for restriction, where:

we have your consent; or

to establish, exercise or defend legal claims; or

Right to data portability: You have the right
to receive the personal information concerning you, which you have
provided to us, in a structured, commonly used and machine-readable format
and you have the right to transmit those data to another entity without
hindrance from us, but in each case only where the processing is (a) based
on your consent or on the performance of a contract with you, and (b) also
carried out by automated means.

Right to object: You have the right to object
at any time to any processing of your personal information which has our
legitimate interests as its legal basis. You may exercise this right
without incurring any costs. If you raise an objection, we have an
opportunity to demonstrate that we have compelling legitimate interests
which override your rights and freedoms. The right to object does not
exist, in particular, if the processing of your personal information is
necessary to take steps prior to entering into a contract or to perform a
contract already concluded.

Right to object to our use of your personal information
for direct marketing purposes: You can request that we change the
manner in which we contact you for marketing purposes. You can request
that we not transfer your personal information to unaffiliated third
parties for the purposes of direct marketing or any other purposes.

Right to withdraw consent: if you have given
us your consent for the processing of your personal information, you have
the right to withdraw your consent at any time, without affecting the
lawfulness of processing based on consent before its withdrawal.

Right to obtain a copy of safeguards: you can
ask to obtain a copy of, or reference to, the safeguards under which your
personal information is transferred outside the EU/EEA. We may redact data
transfer agreements to protect commercial terms.

Right to lodge a complaint with your local supervisory
authority: You have a right to lodge a complaint with your local
supervisory authority if you have concerns about how we are processing
your personal information. We ask that you please attempt to resolve any
issue with us first, although you have a right to contact your supervisory
authority at any time.